ML20039B058
| ML20039B058 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/17/1981 |
| From: | Webb D MENTOR, KY, WEBB, D.F. |
| To: | |
| References | |
| NUDOCS 8112220238 | |
| Download: ML20039B058 (2) | |
Text
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- j UNITED STATES OF AMERICA ve a:T(rn NUCLEAR REGULAIORY COMMISSION
" 57: '
ATOMIC SAFETY AND LICENSING BOARD
'81 EC 17 P2:04 John H. Frye, III, Chairman N
Dr. Frank F. Hooper, Member
. - I E 3E i; :. f
- . Q'i ? SERVICE Mr. Stanley Livingston, Member r.JCH In the Matter of CINCINNATI GAS AND ELECTRIC CO., et al.
Docke (Wm. H. Zimmer Nuclear Power Station, Unit 1) 4 s
MOTION FOR RECONSIDERATION IN PART NCyg' 0F IKE PREHEARING CONFERENCE ORDER OF DECEVBER 3, 1981
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BY THE CITY OF MENTOR b c3 8J 3]
Comes the City of Mentor and requests the Board pursuant 10 C.F.R.12.
b, to reconsider its prehearirg conference order of December 3,1981'igso far as x.
that order on page 26 appoints counsel for ZAC-ZACK as lead intervenor. The City of Mentor has no objections to counsel for ZAC-ZACK handling all cross-examination and presentation of evidence on those contentions by the City of Mentor which have been consolidated with the contentions of ZAC-ZACK. However, the City of Mentor requests this Board for an order allowing it to proceed on contentions two (2), three (3), four 1 (41) and f our k (4k), which said contentions have not been consolidated, and are not otherwise similar to the contentions pursued by ZAC-ZACk, independently of ZAC-ZACK.
As further grounds for said motion the City of Mentor states that contention wo(2) concerns the absence from or lack of written Standard Operating Pro-cedures in the Kentucky and Campbell County Radiological Emergency Plans. ZAC-ZACK has no similar contention. The City of Mentor's contention number three (3) concerns the lack of radiological emergency plans for the State of Indiana.
ZAC-ZACK hac no similar contention. The City of Mentor's contention number four 1 (41) attacks the adequacy of the prompt notification system for Campbell County, Kentucky. Again, ZAC-ZACk has no similar contention. Contention number g63
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four k (4k) alleges that tha wat".r sy2temsfer the entira 50 mile em:rgency plannin6 zone are vunerable to radiation exposure and that there are no plans or insufficient plans to protect the public from this danger.
ZAC-ZACK has not raised this contention or a similar contention.
The City of Mentor further states that at the time of the Board's order the City of Mentor was not represented by counsel. The City of Mentor has now appointed the undersigned, who is licensed and admitted to practice in the State of Kentucky, to pursue, protect and represent the City's interests in so far as those interests are not co-existent with ZAC-ZACK's.
I b E ld b b N i. b 4 i t
Deborah Faber Webb 7967 Alexandria Pike Alexandria, Kentucky 41001 l
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